hdrWalesNDCS Cymru response to Ministerial comments on Close the Gap Petition


Petition P-04-481, April 2017


NDCS Cymru is grateful for the opportunity to comment on the Minister’s response of 11.04.17 in relation to our correspondence of February 2017.

As previously outlined, we welcome many of the points identified by the Minister. However, much of the response outlines initiatives that span across the ALN spectrum and does not address our specific calls for deafness to be included.  As such, further assurances and commitments are required to ensure that these generic initiatives will benefit deaf learners.

Teacher Training

For the young deaf people submitting the original petition, the need to increase deaf awareness among staff was of paramount importance. This is an issue that continues to hold prominence for many deaf young people in Wales. In addition, school teachers have also told NDCS Cymru that they have a need for specific deaf awareness training.

While we welcome the inclusion of ALN within the new Initial Teacher Education accreditation criteria, we remain concerned that there is no direct reference to basic deaf awareness. As such, we are unconvinced that training providers will specifically cover deafness.

This is a real issue. In many instances, deaf awareness is not just about including a deaf child, but can also be about acknowledging that a child has a hearing loss in the first place. Indeed, there is a general misconception that assistive listening devices restore typical hearing levels, which they do not. Therefore, a learner’s deafness can often go unacknowledged.

We seek a commitment from the Welsh Government that ITE providers will have a clear expectation placed on them to cover basic deaf awareness.

Furthermore, we acknowledge that the recently published ITE accreditation criteria outlines the possibility of a thematic Estyn inspection report on ALN within ITE courses. We welcome this suggestion and urge that such a report specifically assesses whether providers are covering discreet ALN needs, including deafness.


ALNCO training

NDCS Cymru is aware of the intention to develop a qualification for the new ALNCo role. We are disappointed that the Welsh Government has not yet determined whether this training programme will cover specialisms such as deafness.

Under the proposed ALN reforms, the ALNCo will play a crucial role in coordinating IDPs and determining which professionals are included within assessments. As such, it is imperative that they have a basic understanding of deafness, as well as an awareness of the specialist advice that should be accessed.


ALN Transformation Programme Funding

We welcome the funding package referred to by the Minister to assist workforce development and to ensure practitioners are fully equipped to deliver the new ALN system. However, we seek assurances that this development will include deaf-specific training.


Acoustics and the 21st Century School Programme

NDCS Cymru welcomes the Minister’s commitment to continue the contractual clause for compliance with acoustic standards within the second wave of investment in the 21st Century School Programme. As with previous changes to contracts, we would welcome the opportunity to work with officials on any alterations to existing wording to ensure the clause remains as robust as possible.

Furthermore, NDCS Cymru notes with interest the following statement on the 21st Century Schools Programme website:

The long term aim is to develop an overarching capital investment programme for all education sectors including both Further and Higher Education Sectors that will aim to deliver priority improvement projects.

As outlined in our initial petition, existing building regulations do not cover FE or HE buildings, other than sixth form colleges that are linked to school buildings. It would, therefore, be imperative to ensure that the contractual clause for the next wave of 21st Century Schools Programme clearly covers FE and HE buildings. Afterall, accessible classrooms are important to learners of all ages.

Furthermore, NDCS Cymru would repeat our calls for the Welsh Government to extend its commitment to good acoustics by amending legislation. This issue was not addressed in the Ministerial response. A change in law would ensure that good acoustics will continue to be on the agenda should the 21st Century Schools Programme come to a close in the future.

In addition, our offer to work with the Welsh Government to raise awareness of measures to improve acoustics in existing buildings within the schools estate was not addressed within the Minister’s response. We would welcome further discussion in this regard.



Workforce planning

As outlined within our former submission, we welcome the review of the specialist education workforce in Wales. We would like to repeat our offer to work with the Welsh Government in this regard. We seek firm assurances that this review will include action to address existing difficulties in accessing Teachers of the Deaf, Communication Support Workers with an appropriate level of BSL and specialist Speech and Language Therapists.


Ongoing monitoring of the attainment gap

The Close the Gap Petition began after Welsh Government statistics revealed significant attainment gaps between deaf children and their peers. In addition to seeking the assurances that we have outlined above, we feel it is imperative that the attainment of deaf learners continues to be monitored so that we can ensure such initiatives are working appropriately.

However, we are concerned that proposals within the Donaldson Review to change the way in which pupil census information is collected would present difficulties for monitoring attainment levels among small cohorts of learners, including deaf pupils. We call on the Welsh Government to ensure that this issue is avoided.



NDCS Cymru is grateful to the Petitions Committee for its ongoing consideration of our Close the Gap petition. In response to our petition, the Welsh Government has outlined a number of initiatives that span across different ALN types. In order to address the attainment gap for deaf learners, a specific focus is required.  At this stage in the process, we seek clear and deaf specific assurances from the Welsh Government.

The key assurances we seek are as follows:

1.  That a clear requirement be placed on ITE providers to include specific deaf awareness training.

2.  That a firm commitment is made to specifically include basic deaf awareness training within the new ALNCo qualification.

3.  That the ALN Transformation Programme includes deaf specific training.

4.  That the Welsh Government works with NDCS Cymru on any alterations to the acoustics clause within future 21st Century School funding contracts.

5.  To ensure that FEIs and HEIs are appropriately covered by the acoustics clause when extending the 21st Century Schools Programme to cover such buildings.

6.  That the Welsh Government works with NDCS Cymru to raise awareness of measures to improve acoustics in existing buildings within the schools estate.

7.  That the workforce planning exercise will specifically address existing issues relating to access to Teachers of the Deaf, Communication Support Workers with an appropriate level of BSL and specialist Speech and Language Therapists.

8.  That ongoing review of attainment levels for deaf learners as a discreet group is not compromised by plans to change the way in which data is collated within the Donaldson Review.

9.  That the Welsh Government commits to keep under review whether sufficient progress in closing the attainment gap between deaf learners and their peers is being made.


NDCS Cymru is happy to assist in further consideration of our petition – please contact campaigns.wales@ndcs.org.uk or call 02920 373474.